Dear Sir,

My comments are to object to the use of sewage sluge in "at risk areas", the 600 acre site in Shenandoah County in specific. The potential risks have already been noted and will again be brought up in the public hearing this April. Here again we finds ourselves with an opportunity to watch our regulatory agencies in this matter, make decisions based on know potential hazards to people and surronding water ways. I wonder just how they would react if this situation was taking place in their own neighborhoods. I support the Riverkeepers in their efforts to clean up our water ways and to make them safe for use today and to protect the ground water that we will be using in the future. It has already been proven that many areas of farm land have been over fertilized simply because the ground is never tested to see if really needs more nutrients and what kind. To make things worse the area in question is in a know flood plain. Will all the sluge be washed away in the next spring storm? Do you know for sure? Do we want to take that risk? I for one do not. I can only hope and pray that these controling acencies will act responsibly, keeping in mind their duty to protect the public, and do what is right for us all. Most of all not be influenced by outside pressures that have other interest in mind.

PLEASE HELP KEEP SLUDGE OUT OF OUR RIVERS WE FISH IN IT PLAY IN IT AND USE THE WATER TO DRINK DO YOU WANT TO DRINK WATER FROM SLUDE. PLEASE DO THE RIGHT THING AND KEEP IT OUT  THANKS                                                                                                                                                                               

When is Virginia going to step up and work shoulder to shoulder with neighboring states and start protecting our water?  The following characteristics make this regulation irresponsible. 

• the land is in a floodplain and its porous rock will flush sludge into the river.
   
• a children's corn maze is located nearby
   
• the site is near a historic bridge and a heavily used river access point
   

The State of Virgina has rubber-stamped the use of sewage sludge on this site, indicating that our state legilators will not protect our water supply from pollution unless the citizens hold them accountable. This is why I have become involved in the fight to change this regulation.

We have the right and the responsibility to demand that our State officials protect our water supply. Listen Virginia legislators! "No Way!" is my response to regulating and allowing sewage sludge to enter our waterways. 

 Systems has been applying biosolids on our farm since 2006. As a landowner there is no one that is more interested in the health of our property and the condition of the land. Daily our cattle recycle waste on the fields maintaining the fertility of the land. It is also a biosolid. Since we have using biosolids from Recyc we have seen an improvement in the condition of our fields with little if any effect on water quality. The main waterway that passes through our farm,Buck Mtn creek has some of the best quality water as monitored by local agencies. The company that spreads the biosolids is careful to maintain appropiate buffers and and avoiding critical slopes and will not cross waterways with their equiptment. Human waste has been used for centuries in some countries such as China. I see no reason why it should not be used here with reasonable oversight and monitoring as I believe is already being done.                                                                                     

The Truth About Sludge as "Free Fertilizer"

Sewage sludge and poultry litter are commonly touted as “free fertilizer.” In fact, all forms of animal waste are highly inefficient forms of fertilization, guaranteeing considerable groundwater and surface water pollution.

The Department of Conservation and Recreation (DCR) is responsible for nonpoint source pollution in Virginia. DCR’s 1995 “Virginia Nutrient Management Standards and Criteria” lists “Estimated Nitrogen Mineralization Rates for Biosolids” in Table 6-1 (p. 64). Mineralization is the release of inorganic nitrogen and phosphorus from the organic animal waste by microbial activity. In the case of lime-stabilized sewage sludge, Table 6-1 indicates that 30% of the applied nitrogen is available to the crop the first year, 15% the second year and 7% the third year. If corn, requiring 120 pounds of nitrogen per acre, is being grown, sewage sludge would be applied at a rate of 400 pounds of nitrogen per acre (400 * 0.3 = 120). It is assumed that the farmer reduces application of chemical nitrogen fertilizer by 15% the second year and by 7% the third year. Presuming that these regulations are followed, approximately half [100 – (30 + 15 + 7) = 48%] the nitrogen in lime-stabilized sludge is not used by crops. Most of the nitrogen not consumed by crops will be oxidized to nitrate and enter the groundwater or contribute to runoff. The United States Geological Survey estimates that half the 50 billion gallons of water that reaches Chesapeake Bay each day is groundwater, discharged underground directly to rivers and waterways. We know that groundwater today typically contains high concentrations of nitrate from agricultural and homeowner practices, so the excess nitrogen from the sludge constitutes additional pollution. Land application designed to fertilize a spring crop will result in mineralization that continues long after the crop has matured and is drying in the field. Late summer temperatures, especially if there is abundant rainfall, will expedite mineralization. High nitrate pollution the summer after land application is guaranteed as nitrate and phosphate are released from the sludge by microbes but not taken up by the crop. Contrast this inefficient form of fertilization with conventional application, ideally split application to row crops, especially in environmentally sensitive soils as DCR recommends. Conventional fertilization minimizes the amount of fertilizer applied to times when it is used by the crop, thus reducing loss to the environment as much as possible. Animal waste fertilization, in stark contrast, is inefficient and results in extensive nitrogen pollution.

All forms of animal waste are rich in phosphorus (P). Only small amounts of phosphorus enter the groundwater (unlike nitrogen), and most phosphorus pollution takes place as the result of runoff, especially if soil is lost. For common soil types, the following table summarizes phosphorus recommendations (from DCR documents) for corn, soybeans and wheat:

Soil Test Level (ppm P)      P recommendations (pounds P/acre)-

        Low             (0 - 6)                  80 - 120

        Medium    (6 - 18)                  40 - 80

        High           (18 - 55)                  20 - 40

        Very High   (55+)                       0

Most soils in the Chesapeake Bay watershed are already High or Very High in phosphorus according to soil tests, and already contain sufficient phosphorus to support crop growth. If VDH regulations were being enforced (12VAC5-585-550.A “The applied nitrogen and phosphorous content of biosolids shall be limited to amounts established to support crop growth.”) sewage sludge could not be applied to most soils. Rates of land application are currently regulated, despite the law quoted above, only by the nitrogen needs of the crop. Most of the excess phosphorus added to the soil as the result of land application of animal wastes is not released to the groundwater as rapidly as is nitrogen, but “banking” phosphorus in the soil guarantees slow long-term release and makes catastrophic loss of P-laden soil much more likely. The phosphorus content of typical sewage sludge is about 2/3 the nitrogen content. Land application of sewage sludge at 400 pounds of nitrogen per acre to meet the nitrogen needs of corn with an expected yield of 120 bushels/acre (it is convenient that about one pound of nitrogen per acre is needed to grow a bushel of corn per acre) will result in application of about 250 pounds of phosphorus per acre. Note that this massive application of phosphorus exceeds any conceivable crop need. Excess phosphorus in most Virginia soils makes Best Management Processes that prevent runoff from fields, and prevent soil from entering waterways, especially critical and in need of strict enforcement.

Farmers who choose to use sewage sludge or poultry litter instead of conventional fertilizer must recognize the inefficiency of this form of fertilization and their role in exacerbating nutrient pollution of Chesapeake Bay. They must recognize that their fields are being used as landfills to dispose of unwanted animal waste in the guise of “free fertilizer.”

Dr. Lynton S. Land, 08/29/04

Myths About Land-Applied Sewage Sludge

 Those promoting the current land application policies don’t just spread sludge.

                                                   They spread myths:

1.  Myth: Sludge is fertilizer.

 Fact: According to the Federal Clean Water Act, sewage sludge is a pollutant.

2.  Myth:  Sludge only contains what’s flushed down household drains or toilets.

Fact: Sludge contains industrial hazardous chemical compounds, toxic metals, surfactants, pharmaceuticals, carcinogens, and disease causing pathogens. Every month, every business and industry in the country is allowed to discharge 33 pounds of hazardous waste into sewage treatment plants. Most of these contaminants concentrate in the resultant sewage sludge.

3.  Myth: Sludge is safe because it is tested.

  Fact:   Only a fraction of the tens of thousands of man-made chemicals in this complex mixture is tested and regulated. Regulating and monitoring individual components, while ignoring the toxicity of breakdown products and interactions, does not assure safety.  A 2002 National Academy of Sciences (NAS) panel warned that the risks of this unpredictable contaminated waste can not be reliably assessed.

4.  Myth: Sludge spreading is safe because it is based on sound science.

  Fact: The NAS panel concluded otherwise. Current state and federal rules are based on outdated or lack of science. Former EPA Deputy Administrator, Paul Gilman admitted that his agency can no longer guarantee the safety of sludge spreading and that the whole issue “has to be revisited.” Because of so many reported “incidents,” EPA no longer promotes land application.

5.  Myth :“Natural biology” breaks down the chemicals; “cooking kills the pathogens.”

  Fact: Toxic metals never break down. They accumulate in the soil or are picked up by animals and plants.  Treatment inactivates most of the indicator pathogens. But more robust disease-causing pathogens can survive and re-grow, especially if sludge is stockpiled in cool and moist climates. One of the most dangerous emerging pathogens, E.coli0157:H7, can survive the treatment process and survive in soil.

6.  Myth: New Hampshire rules are among the strictest in the nation.

    Fact: Totally false.  NH sludge management rules are among the most lenient in the nation.   NH permits lengthy stockpiling, grazing on sludged dairy pastures, mixing sewage sludge with industrial sludge, has no pH monitoring requirement, permits sludge (at 500 tons per acre!) on spent sand pits located above stratified drift aquifers, and does not require sludge to be incorporated into the soil.

7.   Myth: Sludge farming is a sustainable practice. You can use sludge forever.

    Fact: The few European countries that still use sludge have much stricter regulations to protect agricultural soil.   The US lets toxic materials accumulate in soils, until there is a 50% yield reduction. By then, farms have been turned into low-level waste dumps. We know of NO published scientific study that indicates that using sludge on farmland or forests is safe or sustainable.

8.  Myth: Class A EQ sludge is so safe you can eat it.

   Fact: Class A EQ sludge can legally contain up to 32 mg/kg of arsenic, 14 mg/kg of cadmium, 10 mg/kg of mercury, 300 mg/kg of lead, copper and zinc way in excess of what is needed for healthy crops, as well as potentially harmful organic chemical compounds and viable disease-causing pathogens. Yet use of this material is essentially unregulated in the state.

9.  Myth: Only a vocal uneducated minority questions the current sludge policies.

    Fact: The National Academy of Sciences is hardly uneducated. Neither are internationally renown soil scientists of the Cornell Waste Management Institute. The National Farmers Union opposes the use of sludge for farming, as do grassroots environmental organizations across nation. Food processing companies such as Heinz and Monsanto will not accept produce grown on sludged land.

10.  Myth: Sludge has never impacted people, livestock, or groundwater. 

   Fact:  False.  Hundreds of sludge-exposed rural people have reported serious respiratory and gastrointestinal illnesses. In Greenland NH, dozens of neighbors got seriously ill, and one young man died, after 610 tons of sludge were chain dragged on a ten acre hayfield located next to their houses. Cattle have been killed by ingesting forage,  grown on sludged fields. New Hampshire and Maine drinking water sources have been impacted. Industry lobbying groups, such as NEBRA, are covering up these reported and documented incidents.

11.  Myth: There are no other solutions to our septage and sludge disposal crisis.

      Fact:  Sludges and other nonrecyclable wastes can and are being used beneficially as a renewable source of clean energy without environmental impacts.

2-23-07      For documentation and additional  information contact info@sludgefacts.org and visitwww.sludgefacts.org

A few resources:

“Toxic Sludge is Good for You!”  Lies, Damn Lies and the Public Relations Industry

by John Stauber and Sheldon Rampton

http://www.whistleblowers.org/index.php?option=com_content&task=view&id=74&Itemid=108

http://www.sludgenews.org/action/story.aspx?id=68

http://cwmi.css.cornell.edu/sewagesludge.htm

http://www.sludgevictims.com/part_503.html

http://thewatchers.us/book/503-preamble-sludge-rule.html

Toxic Sludge as Fertilizer on Farms--A Major Threat (http://www.organicconsumers.org/Toxic/062603_sludge.cfm)

http://www.organicconsumers.org/sludge.cfm -

(http://cwmi.css.cornell.edu/Sludge/Newsolutions.pdf) -

Soil Analysis - Kinsey Ag, www.kinseyag.com.  

If you have a facebook page there are  several sludge related articles posted on the discussion page.

https://www.facebook.com/pages/SLUDGE-ITS-WHATS-FOR-DINNER/133345120020541?ref=ts

Please use common sense and all the data available to stop the plan to put sewage into our (the public's) streams.    

This topic might not be very kawaii or so cute but it's still important and should be discussed! 

It seems like absolute insanity to dump sewage sludge into a floodplain near a children's play area.  If  that doesn't seem like a health risk to you why not just dump it into the river and be done with it.  In essence it's the same thing.  Certainly a better solution can be found!

Cats learn to use a litter box. Dogs can be house broken, and we potty train our children. So why would the state of Viriginia basically allow big business to take a poop in our drinking water? If you pulled your drinking water from a pond at the bottom of a hill, would you build yoru outhouse on the slope above it?

Virginia must take steps to better regulate the application of products such as biosludge. Maybe a first step is to call it what it really is: processed poop.

Please consider regulations that prohibit the application of these products in the flood plain, near places where people live or chilren play or go to school, or in areas that could contaminate drinking water.

It's depressing to drive to a beautiful rural spot on the Rapidan River on RT522, prepare to put in my kayak to fish, only to see signs along the field by the highway and river publicizing the use of biosludge on land that floods every year. I couldn't help but wonder that day I fished what exactly was IN the water along with the smallmouth bass I love to chase and guide other fishermen to.

Ecotourism is a large business in Virginia. Some of my clients come to areas I fish because of the beauty, and the relatively clean water that flows through these streams. If Virginia gains a reputation for deliberately allowing biosludge or other unsavory sounding products to filter into our rivers, the message will damage our economy as people choose to travel to other destinations to fish, costing us sales tax revenue and restaraunts and hotels income.

Regulate the use of these substances to protect our water ways from the harmful impacts of the increased nitrogen and phosphorus load caused by unoff after rainfall on treated properties. I have no desire to fish and swim in a river filled with this crap after our sewage treatment plants have worked so hard to remove it from their discharge. I hope the cats and dogs live together in peace before Virginia will allow these practices to continue.

It would be impossible for me to top what Mr. Pfotenhauer said in the prevous comment. Especially his metaphor about building an outhouse on a slope above a drinking water source. That's exactly what the application of these biosolids equates to. Please use some common sense and protect our water.

I am not well versed in the subject of sluge, and am completely new to the proposed legislative action. But I am learning fast, having been alterted to the issue by local conservation organizations and informed by the comments on this site, especially the very helpful information provided by Joy Lorien, above.

However, I am a life-long user of Virginia's waterways. I am encouraged by the improvements I've seen in water quality since the enactment of clean air and clean water legislation in my youth. When I was a child, fisheries were quite threatened (my term, not a technical reference) by pollution. In the 1960's I grew up near the James River, but never saw eagles nesting, Heron rookeries, etc. Today, thanks largely to smart environmental policy decisions made about 40 years ago, river environments are surging back to health. Today, eagle sightings are becoming commonplace.

But in the current political environment, the gains of the last 40 years are eroding. When I see legislation that changes the word "sludge" to "bio-solids," I smell a linguistic cover-up. Let's face it, we are talking about putting sewage almost directly into waterways and calling it "bio-solids." 

Commenters above have done a much better job than I can of exposing the differences between humans' historical use of sewage as fertilizer and the current use of "sluge" that contains a poisonous package of pollutants. Please heed these warnings.

I would add that one only has to look at recent history to find woeful precedents that may apply to this situation. Just look at the regulatory neglect that allowed wall street to run amok and nearly ruin our economy - and here we are talking about trusting to a regulatory process to keep the dangers of sewage sludge in check. One only has to look at the current nuclear crisis in Japan to see how poorly a for profit corporation protected the Japanese public from disaster - and here we are talking about trusting to corporations to properly manage the application of sewage sludge.

Sewage sludge is not going to crash our economy or irradiate our population, but this sludge is clearly dangerous stuff. Please do not trust to a regulatory process and corporations motivated by profit to manage this. Please keep sewage sludge out of our waterways. I would like to keep enjoying the sight of Eagles and would like future generations to enjoy them also.

John Moser 

Please don't allow any more fecal waste, human or othewise in one of the best fisheries in the Eastern U.S.  There is already too much flowing off fields and out of obsole treatment plants.  If you get out and wade them and then check yourself for sores, or open up a male smallmouth and look at the eggs I think you will see my point.

Sincerely,

George Paine

Secretary and Fish with a Member Chair

N. Virginia Chapter of Trout Unlimited

(800 plus members_

This topic might not be very

or

but it's still important and should be discussed!

The spreading of sludge on farmers fields brings the following to mind: I am not a scientist, but intuitively, don't most of the creatures we share this planet with avoid fouling their own nest?  If the ever increasing billions of humans persist in doing so, where will WE live, much less those other mammals and birds and fishes?  If this is the inevitable consequence of growth, then it's time we find an alternative to growth.

This is insanity. Over the last few years, documented fish kills on the Shenandoah, Jackson and James Rivers, to name a few, have been tied to the increased use of sludge as a fertilizer on watersheds in these rivers. if the increased pollution generated by runoff from these treated areas is killing fish, what else is it doing to to the users downstream.

This is not using sludge as fertilizer, it is using rivers as waste disposal dumps.  Your agency is charged with protecting rivers, and the environment as a whole, not protecting the financial interest of a few well connected industrial chicken farmers.  To even consider loosening the standards, weak as they are, borders on the criminal.  These standards should be tightened to the point that the industrial farmers should be required to dispose of the waste in a safe, non-polluting, non-health endangering manner, and this disposal cost should be born by those who generate the waste, as a cost of doing business.

It is time that political considerations are put aside and common sense is applied to the use of our Commonwealths waters, lands and air.  I hope that you will agree that sludge is a problem that does not need to be visited upon our waters, not a solution for a few politically well connected businessmen.

As a member of the BASS Federation of America, Virgina Chapter, I apose anything that weakens water quality in the already over nutrified Shennandoah and Potomac Basin.  To speak clearly, this plan craps on the Potomac River and Shenandoah.  Are you aware the Potomac has hosted  hundreds professional bass fishing tournaments and generates millions of dollars annualy in recreation related sales taxes?

Thousands of people travel from out of state each year to fish these rivers, shopping in our malls and staying in our hotels.  A 10th grader could add up these economic benefits better than Governor McDonald's "Environmental team".  As a fisherman concerned with the economy, I am embarrased by the Govornors stance on fighting the EPA's modest goals to clean up our rivers and the bay.  I certainly apose spreading sewage sludge anywhere near floodplains.

Our recreational resources have tremendous economic development potential if managed intelligently. Sales tax receipts, clean recreational tourism, a cleaner river.  This is a virtuous circle that should be our guiding principle in matters that effect our rivers, our state treasures.

Let's not turn our town into a tonsillar stones!

I cannot believe that you are considering dumping Sludge anywhere near the Shennandoah River. This River is already on the endangered list. Besides, there is a children's maze nearby and a bed and breakfast. This is an area that is frequented by fisherman and familes. Many of the fish have been killed by runoff from chicken farms already. Do you have to make it worse. I thought that you are responsible for saving our waterways not distroying them! Please reconsider.

I work for Long and Associates Environmental Services, Inc. as a WWTP startup operator and as a troubleshooter for failing treatment plants, including VDOT rest areas. I farm and raise Texas Longhorns. I singlehandedly successfully performed the startup of the $9 M Warsaw Enhanced Nutrient Reduction plant in 2010. I know "sludge", good and bad. The application of biomass for farming is an emotional issue as evidenced by the comments, largely because most people are completely uninformed and have been conditioned to consider sludge as nuclear material. Properly stabilized sludge is a natural affordable and more controlled alternative to chemical fertilizers. Given that the price of pertoleum, the source of fertilizer, is soaring; properly stabilized and professionally applied biomass is an excellent solution. I apply biosolids on my land. I maintain a current Nutrient Management Plan as well as Application Records on my land. I submit that I know more about my land's health (pH, soil samples, weed applications) than most homeowners who buy several bags of Scott's and apply all of it foor good measure, more is always better. How many homeowners keep records of their applications? The answer is none and most of the excess fertilizers and insecticides they apply runs off with the rain into the nearest receiving stream, fish kill anyone? Let's face it, the current regulations for applying biomass work. They do not need fixing. If you want to control environmental degradation, look at applying the same standards to suburbia and the homeowner that are applied to the farmer. 

I would like to commend this committee for its work on this highly controversial subject.  I, unlike most of the people commenting, have gone over the entire text regarding the Amendment of Regulations Pertaining to Biosolids (200+ pages)

First, I would like to make an observation regarding the previous 22 comments made.  People seem to be mostly concerned with sludge/biosolids entering the water via groundwater or through runoff into rivers and streams.  They are worried about illnesses resulting from toxic substances in these biosolids.  It is also apparent that there is a lack of trust concerning E.P.A. and D.E.Q.'s past actions in this area and people believe big business, local connections, and outside interference will permit practices that would otherwise be prohibited.  One third of the comments were from people that were concerned and frustrated, but clearly did not have the time or knowledge to write any substantial feedback.  One individual is obviously adamant about their concerns but does not provide any constructive advice or objectivity regarding the true problems and solutions of Wastewater Treatment Plant sludge disposal, (myths not withstanding).  

Mr. Kent Cuthbertson mirrors my opinion best in stating; "The application of biomass for farming is an emotional issue as evidenced by the comments, largely because most people are completely uninformed and have been conditioned to consider sludge as nuclear material. Properly stabilized sludge is a natural affordable and more controlled alternative to chemical fertilizers. Given that the price of petroleum, the source of fertilizer, is soaring; properly stabilized and professionally applied biomass is an excellent solution." 

The lack of knowledge by people concerned about toxins, diseases, and lack of oversight and monitoring procedures is astounding.  No one has pointed out the importance of differentiating the terms "sludge" and "biosolids".  It is quite significant as untreated "sludge" is very rarely if ever applied directly to land. Biosolids, which are of a particular class of treated sludge, are in fact commonly applied to land.  As Mr. Cuthbertson has so accurately referred to in his comments: properly stabilized and professionally applied biosolids present no potential harm to waterways or humans by way of pathogens or metals contained within them.

I will readily admit that I do not like the idea of Class B biosolids being applied to lands when they could be converted to Class A biosolids with very little additional effort and expense.  What I do object to is when Class B biosolids are being dumped into a landfill at considerable expense and harm to the environment while wasting a potentially valuable resource for our land.

I do believe and agree with previous comments that this committee needs to be more proactive in researching and encouraging solutions pertaining to recycling of biosolids.  Not one person made mention of an innovative, affordable, and environmentally sound method called vermicomposting or vermistabilization of sludge.  It makes no sense at all to me to put any class of biosolid onto soils without inoculating that soil with earthworms first.   

The vermistabilization process requires 3 classes of earthworms, (Redworms, gardenworms, and nightcrawlers) a piece of land, and a device to apply the biosolids in a continuous layering method that is controlled and monitored for effective operation.  The worms eat the microbes generated from the biosolids, and eliminate any odors and pathogens while producing castings that serve as a rich organic humic substance that replaces and replenishes the nutrients in soils that are otherwise lost to soil erosion from fires, floods, and poor agricultural practices.  Numerous benefits occur from these castings including: providing soils with excellent aeration, porosity, structure, drainage, and moisture holding capacity; a lower pH then the applied sludge due to CO2 and organic acids from microbial metabolism; timed release of nutrients N, P, K through the breakdown of a mucus membrane surrounding the castings which produces  more soluble minerals that can be more readily absorbed by plant roots increasing plant growth up to 20% and root mass 150%;  a reduction in harmful bacteria and diseases in crops by the production of a huge increase in benevolent disease suppressing microbes that crowd out harmful diseases, pests and pathogens by as much as 72% due to an aerobic environment that is created; a nutrient rich organic fertilizer that provides up to 7x K, 5x N, and 1.5 x Ca than in surrounding topsoil; a more neutral pH that will not burn plants, a reduction of carbon emissions into the air; a reduction in the potential for harmful inorganic chemicals leaching into water systems; less possibility for soil erosion, increased crop yields and overall income to farmers; less labor costs and disruption of soil from tilling practices;  and best of all – the converted biosolid meets Part 503 Class A PFRP requirements.  The process is flexible to be used in conjunction with other methods, can be done indoors or outdoors, and is able to be managed and monitored without the exorbitant capital costs and energy usage that is common with thermophillic methods.  This successful technology is being used in many other countries such as England, Canada, India, Mexico, Australia, Philippines, and others.

The National Academy of Sciences (NAS) has proposed a study to review the science behind the federal government's laws on applying biosolids to land.   The $531,000, 18-month project would review new information on biosolids land application (vermistabilization?) and evaluate EPA's methods of determining risk from chemicals and pathogens in biosolids. All aspects of the Part 503 risk assessment will be examined, including the identification of pollutants, exposure pathways, default assumptions, and others.  (What a great opportunity to explore vermistabilization as an alternative method to meeting Part 503 requirements.) 

Better scientific tools are available now to help EPA gather needed data and monitor land-application practices. Science does not remain static, nor should our efforts to protect public health and the environment.  Thomas A. Burke, Ph.D.

http://www.epa.gov/waterscience/biosolids/nas/complete.pdf

Biosolids frequently asked questions website listed above.

A new Washington Post piece by Darryl Fears claims sewage sludge is safe enough to put in your mouth. Specifically, the statement was made about "Class A Biosolids," the treated sewage sludge (renamed "biosolids" to make it sound less unpleasant) that has regulated amounts of 10 heavy metals, salmonella, and fecal coliform.

What else might you find in sewage sludge? Well... Alkylphenols and alkylphenol ethoxylates, dioxins and furans, flame retardants, heavy metals (including some that are not regulated), hormones, pesticides, perfluorinated compounds, pharmaceuticals, phthalates, polycyclic aromatic hydrogens, steroids, and more... Still wanna put that in your mouth?

Fears was not advocating that anyone put sewage sludge in their mouths... at least, not directly. The article was instead about how sludge should be used as fertilizer for food crops... which people would then put in their mouths.

For the past year, on and off, I've been working with the Center for Media & Democracy's Food Rights Network, a group that opposes the use of sewage sludge as fertilizer on food crops. So, full disclosure, I've been getting paid to research the hell out of sewage sludge and to write about it. I've even been paid to go to my local Home Depot and buy three bags of sludge compost to send samples to a lab for testing. And let me tell you... if the long list of sludge contaminants and the EPA's own record of what they found in sewage sludge doesn't scare you off of using sludge as fertilizer, the smell of it will. It's not a poop smell - it's a chemical smell. An incredibly volatile, potent one.

The question is, of course, what are you putting in your mouth when you eat food grown in sludge? And the answers are: "We don't know" and "That depends." We don't know because it's almost entirely unregulated and because there are an awful lot of chemicals out there that just haven't been studied well enough to have the answers. Additionally, once you finish studying each individual chemical, then you'd have to study all of the combinations to see what happens when you mix them together in a toxic goop and apply them to farms and gardens. And it depends because each batch of sewage sludge is different, based on which households, hospitals, and industries are contributing to the waste stream and what they've put down the drain that particular day or week.

For farmer Andy McElmurray, it depended that a Nutrasweet plant was dumping thallium (rat poison) - an unregulated contaminant in sewage sludge - into the waste stream. The thallium went from the sludge applied to his soil, to his forage crops, to his cows, and all the way to the milk he sold to grocery stores. He only found out about the hazards of sludge after an extensive investigation into why his cows were dropping dead one after the other. McElmurray and his dad both got sick from working around sludge, and the farm went out of business. Dairying isn't very profitable when your cows are all dead.

Fears notes the sludge industry's favorite talking point: We have all of this human waste, and what are we going to do with it? Well, what should we do with pesticides, perfluorinated compounds, and flame retardants? I don't know. I don't think there's a good answer. In the case of some of the most common flame retardants (PBDEs), the world's answer was to ban them in the Stockholm Convention on Persistent Organic Pollutants. I think that's a step in the right direction. The problem is that "persistent" refers to the fact that this stuff doesn't break down. The answers to the sludge problem are upstream ones. We shouldn't make such toxic substances if we don't have a way to dispose of them. So, sure, it's a problem to figure out where to put all of the sewage sludge. But lying that it's safe and then selling it to unsuspecting gardeners ain't the answer.

Another favorite sludge talking point in the article is that manure, including human poop, is "the world's original fertilizer." And, sure, the Chinese were famous for using night soil as fertilizer (one reason why you don't see salads on the menu at Chinese restaurants... all the veggies are cooked in Chinese cuisine). But the pre-industrial Chinese were not manufacturing and mixing toxic chemicals in with their night soil.

So go ahead, Darryl Fears, put some class A biosolids in your mouth. Or, let's make it more pleasant... how about a carrot grown in them? Still wanna eat that?

Jill Richardson :: I Dare You: Put Sewage Sludge in Your Mouth

Over the past decade, we have provided numerous reports, scientific papers and detailed memos to both Virginia DEQ and DCR in support of the use of one-time applications of biosolids to newly reclaimed mined (or similarly disturbed) lands that are higher than would be allowed under a typical nutrient management plan framework for established cropping systems on agricultural lands. Our recommended loading rates for these one-time applications have ranged from 25 to 35 dry tons per acre for the purpose of rebuilding soil organic matter and nutrient reserves for long-term soil building benefits. In our detailed submissions, we have provided ample evidence from three different mining sites that this practice does not lead to significant leaching of nitrate-N to local shallow ground water. However, the current proposed regulations still stipulate that a conventional nutrient management plan must be approved by DCR for all mined land applications. Our long-term research results clearly indicate that (A) this approach is not valid for these kinds of drastically disturbed sites and  (B) significant long term soil building and revegetation benefits are lost when biosolids applications are  limited to conventional rates for reclamation sites.

Additionally, the current regulations contain no language allowing DEQ to permit the use of higher rates of biosolids as a part of research programs or when clear emergency situations (e.g. Stafford Airport project in 2001/2002) demand their utilization. As currently written, we would be required to submit a conventional nutrient management plan for approval of any research plots. Since one of our goals in performing field research would be to investigate the net soil and water quality effects of higher than agronomic rates, this requirement is obviously self-limiting and senseless. Furthermore, the turn-around time for review and approval by DCR is of great concern to us. Similarly, there is no language whatsoever that would allow DEQ to waive conventional nutrient management plan requirements for emergency situations.  Historically,  both of these scenarios (research plots and emergencies) always involve submission and approval of detailed soil and water quality monitoring plans that are much more stringent that conventional land application permit requirements. Therefore, we feel strongly that language should be added to the final proposed language to allow DEQ discretion in approving both research and emergency application use of biosolids at higher than conventional rates without conventional nutrient management plan approval restrictions. 

The Maryland Environmental Service is a not-for-profit, State of Maryland agency that conducts many diverse projects in the environmental field. One of those ongoing projects for the past 27 years involves performing independent third-party land application inspection services on behalf of several biosolids generators in the region. Our program and the experience of our staff give us a unique perspective on biosolids land application.

MES believes that biosolids land application is a safe practice that poses insignificant risk when done properly.  We feel that the proposed regulations are protective of public health and the environment. We do however have several specific comments with respect to these proposed regulations. These comments are noted below:

1.          Section 9VAC25-31-10. Definitions

            It appears that the definition of Publicly Owned Treatment Works (POTW) is listed twice

2.          Section 9VAC25-31-100 7.a.. Application for a permit.

            MES agrees with DEQ that sampling for PCBs is appropriate.

3.          Section 9VAC25-32-60. F.1. c. (3) Application for a VPA permit.

            MES agrees with DEQ that implementing odor control plans are a good idea, since odors are a major issue of concern at land application sites. We would go one step further, and suggest that the there should also be a requirement in the odor control plans for both the generators and land appliers to have a system for recording and documenting odor complaints. An odor control plan to minimize odor complaints will be more robust when the complaint information is transmitted to the source (generator).

4.    Section 9VAC25-32-60. F.2. d. (3) (h)  Application for a VPA permit.

            The definition of gross acreage should be defined more clearly, and there should be some reference to usable acreage (the gross acreage minus the buffer zone areas).    

            Our experience has shown that the differences between gross and usable acreages should be delineated so as to avoid confusion in the field during land application.

            Also, it’s common practice for land appliers to flag fields to mark off the buffer zone areas. MES suggest that the field flagging procedure be incorporated in the regulations to make this a universal practice.

5.    Section 9VAC25-32-307 A.  Relationship to other regulations

            This section refers to the Solid Waste Management Regulations at 9VAC20-80-10 et seq. MES believes that these regulations were repealed in March 2011 and replaced with 9VAC20-81-10 et seq.

6.    Section 9VAC25-32-545.  Staging of biosolids for land application

            This section requires some clarification. For example, when will the land appliers be allowed to stage material - after an equipment breakdown? What event triggers the need for staging biosolids? Also, some of the timing issues and length of staging need to be clarified as well.

7.    Section 9VAC25-32-550.D.5.f  Storage Facilities

            The proposed language states “If malodors related to the stored biosolids are verified by DEQ at any occupied dwelling on surrounding property, the malodor must be corrected within 48 hours”. What criteria will DEQ use to verify when nuisance odors are a problem? It’s well known that solving odor problems is very subjective science.

            On another note, MES commends DEQ for their progressive approach to the storage regulations to include covers, truck washing, supernatant management, and other good management practices.

I urge you to reconsider approving the legislation as proposed. I oppose the proposed amendments pertaining to the regulations on “biosolids” as a concerned citizen of the Commonwealth of Virginia and a professional environmental auditor with 30 years of experience.  The proposed amendments seem to be driven by generating fees associated with dubious practices rather than the desire to ensure the health and wellbeing of Virginia’s citizens. Changing the term “sewage sludge” to “biosolids” 493 times in written law without defining it disingenuous and confusing. 

I completely support the comments of those who are either out rightly opposed to sludge applications or who urge extreme caution. I especially agree with Dave Gibson and Diane Parker, both are right on point.

Instead spending limited resources discussing setbacks, fee schedules, etc. maybe those resources should be used to find viable alternative uses like converting it to energy.  Or a testing protocol that goes far beyond what EPA has done. The agricultural community and citizens of the Commonwealth have a right to know what hazards they are being exposed to be it airborne pathogens, plant uptake or polluted waterways.

USEPA and its 503 Rule has a very dark cloud hanging over it, the same cloud hung over VDH. I hope DEQ will not be darkened by this same cloud.

I think you do the DEQ a disservice when your document states that sludge is commonly referred as biosolids, that may be the case at DEQ and in the sludge industry but the common term amongst concerned citizens is sludge. Repeatedly doing so gives the appearance that DEQ has lost its objectivity.

It appears to me that the proposed regulation works against the state's attempt to clean up the Chesapeake Bay. The state has appropriated funds and conducted numerous studies to find ways to stop polluting the bay. One of the ways the bay is currently being polluted is by rain water runoff from polluted pasture and farm lands. This regulation would appear to increase the amount of pollutants on those lands, thus complicating the bay cleanup effort.

This plan is so obviously flawed I suspect there is skulduggery afoot. I will write to State Attorney General Cuccinelli requesting an immediate investigation to determine if my suspicions are correct. It just doesn't seem possible that the state would work against its own cleanup effort unless there were some sort of payoff involved.

William Norris

P.O. Box 1105

Richmond, VA  23218

Dear Sir:

The following comments on “Amendment of Regulations Pertaining to Biosolids After Transfer from the Virginia Department of Health - Virginia Pollution Abatement Permit Regulation (Primary) ; Virginia Pollutant Discharge Elimination System Permit Regulation; Fees for Permits and Certificates” are filed on behalf of the 400 member of the Friends of the North Fork of the Shenandoah River.  In the interest of brevity, our comments are specific to proposed changes to VPA Regulations.  Please apply them to comparable sections of VPDES Regulations. 

Although we recognize the need to dispose of treated sewage sludge and that land application may be appropriate under some circumstances, as indicated in our statement at the April 7, 2011 public hearing, we are concerned that the proposed regulations do not adequately protect the environment and natural resources of the Commonwealth. Specifically, the revised regulations do not adequately address (1) the largely unknown content of the sludge, (2) application to geologically vulnerable sites, and (3) insufficient permit requirements to ensure the protection of the environment or human health. 

Contents of the sludge:  Given the largely unknown chemical composition of sewage sludge and the resultant lack of information regarding the fate, transport and effects of these materials, much more stringent regulations are required to ensure the protection of human health and the environment.  According to the Deputy Commissioner of the Virginia Department of Health (letter to DEQ dated May 2, 2008), it is not possible to make a definitive statement about the safety of sludge because we do not know the actual contents of the sludge and there is a complete lack of knowledge regarding the health  and environmental effects of some of the contaminants that may be present in the sludge.  The Panel of Experts convened by the Secretaries of Natural Resources and Health and Human Services to study the impact of land application of biosolids also concluded that insufficient information exists to determine the long term effects of these materials on wildlife or water quality (Final Report, January 2009)

What we do know is that sewage treatment plants are not designed to remove many of the chemicals that are currently entering the waste stream.  Emerging contaminants of concern are being found in waterways across the country, including the North Fork of the Shenandoah River.  Because these chemicals are not removed in the treatment process, they also end up in the sludge.  In its recent “Targeted National Sewage Sludge Survey Report, January 2009) the U.S. EPA reported finding 145 different chemicals in sewage sludge from 74 sewage treatment plants in 35 states.  In addition to nitrates and phosphorus, almost every sample contained metals, organics and hydrocarbons, pharmaceuticals, steroids, hormones and flame retardants.  Overall, 27 different metals were detected in virtually every sludge sample analyzed.  Despite language in the state regulations stating that “biosolids may be required to be tested for certain organic compounds prior to agricultural use”, the draft regulations require analysis for only 9 heavy metals (only 1/3 of those EPA found in every sample).   Concluding that this minimal requirement for chemical characterization of sewage sludge applied to agricultural land will be protective of human health and the environment defies logic.  We will know nothing about what else is being dumped along the river and potentially entering our drinking water supplies.

To ensure the protection of surface and groundwater resources, the regulations should require a more complete chemical characterization of sewage sludge.  All biosolids permitted for land application should first be monitored for an expanded list of pollutants that are known to occur in sewage sludge.  At a minimum, 9VAC25-32-356 Pollutant Limits should be revised to require biosolids be analyzed for aluminum, barium, beryllium, boron, calcium, manganese and silver (identified by EPA as metals of concern in sewage sludge).   Because sludge can come from municipal sources and may affect drinking water sources, analyses of class B biosolids should also include the organic chemicals listed in Table 1 at 9VAC25-32-570.  The rationale given for not requiring more thorough chemical analyses is “primarily… the lack of a scientific basis for the inclusion of additional parameters”.  In the absence of definitive proof to the contrary, DEQ assumes that these materials will be safe. 

Given the weight of circumstantial evidence indicating the prudence of including additional chemical analyses and the total lack of scientific evidence to support the safety of these materials, a more conservative regulatory approach is warranted.   U.S. EPA’s Part 503 specifically allows states to adopt more stringent requirements than those enumerated in the guidance.   The Endocrine Society is concerned that the public may be placed at risk due to the proliferation of new chemical compounds in the environment and their potential to cause adverse effects at very low levels.  Of specific concern to them are endocrine disrupting compounds (EDCs), and they recommend “Until such time as conclusive scientific evidence exists to either prove or disprove harmful effects of substances, a precautionary approach should be taken in the formulation of  EDC policy” (Postion Statement on Endocrine-Disrupting Chemicals, June 2009).  Field studies from around the world have demonstrated that very low concentrations of some endocrine disrupting compounds can significantly affect natural populations of aquatic vertebrates.  Work conducted by the U.S.G.S. found a very high rate of intersex in bass from the Potomac and its tributaries, and also quantified EDCs in their blood (Blazer, et al, 2007, Journal of Aquatic Animal Health; Chambers and Leiker, 2006, U.S.G.S. Report 2006-1393).  The U.S. EPA is sufficiently concerned about the potential effects of emerging contaminants that they have undertaken a special review to determine how best to facilitate development of aquatic life criteria for compounds that, among other things,  may cause adverse effects at very low levels (U.S. EPA White Paper “Aquatic Life Criteria for Contaminant of Emerging Concern, Part I, June 2008). It is time for the burden of proof to be shifted to require that biosolids be proven to be safe prior to being land applied throughout the Commonwealth.

Geologically Sensitive Sites:  Given an incomplete analysis of what is in the specific sewage sludge and the lack of scientific information regarding the fate, transport and environmental effects of many of the chemicals that may be found in sewage sludge, DEQ cannot confidently determine what an adequate setback distance will be to protect water quality, aquatic organisms, endangered species or human health.  The buffer zone requirements recommended in 9VAC25-32-560 (Table 2) are different for different types of water bodies (perennial streams, intermittent streams, sinkholes, agricultural drainage ditches).  These different distances seem to be indicative of the uncertainty regarding what is an adequate buffer to protect water sources.  Dr. Greg Evanylo of the Department of Crop and Soil Environmental Sciences at Virginia Tech has cautioned that potentially unsuitable areas for sludge application include: areas bordered by ponds, lakes, rivers, and streams, steep areas with sharp relief, areas of karst geology, rocky, shallow soil, and other environmentally sensitive areas, such as floodplains (Virginia Cooperative Extension Publication 452-300).  Given the prevalence of these features in areas of karst geology, the interaction between surface water and groundwater in these areas, the heavy dependence on wells for drinking water in agricultural areas and the lack of chemical-specific information to determine adequate buffers regulations need to err on the side of safety in these environmentally sensitive sites.  Because the adequacy (i.e., protectiveness) of a buffer cannot be established with any certainty, application of sludge in areas of karst geology and  floodplains poses an unacceptable risk of contamination of surface and groundwater, both of which serve as drinking water sources.  9VAC25-32-560 should prohibit land application of biosolids on areas designated as floodplains, on karst landscapes characterized by limestone outcroppings, sinkholes, solution channels, and caves and on slopes greater than 7%.   Barring that, minimum buffers around all environmental features listed in Table 2 should at least equal the 35 foot buffer required by NRCS standards, regardless of the method of application.

Permit Requirements:  Standard permit requirements should be prescriptive enough to ensure protection of human health and the environment in all cases.  Providing DEQ the ability to add conditions on a case-by-case basis to account for situations that may warrant additional scrutiny is not sufficient.  DEQ has demonstrated an unwillingness to address unique situations (such as karst geology).  This is understandable because there is a lot of pushback from applicants to not require anything over and above the bare minimum allowed by the regulations.  Therefore, the regulations must be strengthened to ensure that all applications of sludge are done in as safe a manner as technologically possible.

Section-by-Section comments:

9VAC25-32-10. Definitions:  Biosolids - Regulations should not change terminology from sewage sludge to biosolids   To support transparency and full disclosure to the public, the regulations should call these materials “treated sewage sludge” or “sewage sludge biosolids”.

Local Monitor – Defining local monitors as “employed by a local government” is too restrictive and may preclude some localities from being able to monitor biosolids applications within their jurisdictions.  Regulations should be revised to define a local monitor as “designated by” or “engaged by” a local government.

9VAC25-32-60.  Application for a VPA Permit. Section F.1.c.(7) General information required should include the exact location of sites proposed for application, such that interested individuals can identify specific fields proposed for application.

Section F.2. a. Biosolids characterization -  Biosolids analytical data should be from samples taken within one (1) year of the permit application.  Allowing analyses that may be 4 or more years old is excessive and may not be representative of the materials that will be applied.

Section F.2.d. Land application sites – topographic maps should depict flood plains, which should be used to determine where biosolids can be applied, rather than “frequently flooded areas”.

9VAC25-32-140.B and C. VPA Permit application – Permit Modifications, a public hearing and a public comment period should be required for any additional acreage proposed to be added to a permit.  Allowing an increase of up to 50% in acreage covered by a permit without any public notice or review is excessive and precludes any review necessary to protect the environment.

Section D.2.A minimum of 15 days should be allowed for public comment after any public hearing on a permit.  The Department should not be allowed to shorten the period.

9VAC25-32-315.C.  Additional and more stringent requirements.  For the reasons stated already, this section of the regulations should prohibit land application of biosolids on areas designated as floodplains, on karst landscapes characterized by limestone outcroppings, sinkholes, solution channels, and caves and on slopes greater than 7%.  

9VAC25-32-356. Pollutant limits.  Biosolids should be monitored for an expanded list of pollutants that are known to be present in sewage sludge.  At a minimum, 9VAC25-32-356 Pollutant Limits should  be revised to require biosolids be analyzed for aluminum, barium, beryllium, boron, calcium, manganese and silver (identified by EPA as metals of concern in sewage sludge).   Because sludge can come from municipal sources and may affect drinking water sources, analyses of class B biosolids should also include the organic chemicals listed in Table 1 at 9VAC25-32-570. 

9VAC32-25-460. Soil monitoring and reporting.  This sections states “Soil shall be sampled and analyzed prior to biosolids application…”, but does not say when soil samples must be taken.  Soil sampling should be required to take place between the last application of fertilizer (in any form, including poultry litter) and the time of application covered by the subject permit.  In no case should samples be taken more than one (1) year prior to the permit application.  Results from a 3-year old analysis (the current requirement) are likely not to be  reflective of actual soil conditions at the time of application. If other fertilizer or soil amendments are applied within the 3-year period, the older soil sample results would be meaningless

9VAC25-32-560.B. Agricultural Use. Section 3.e.(3) Slopes – should be revised to state “Biosolids should not be applied to slopes in excess of 7%”

Section 3.f. Buffer zones.  Because the adequacy (i.e., protectiveness) of a buffer cannot be established with any certainty, application of sludge in areas of karst geology and  floodplains poses an unacceptable risk of contamination of surface and groundwater, both of which serve as drinking water sources.  9VAC25-32-560 should prohibit land application of biosolids on areas designated as floodplains, on karst landscapes characterized by limestone outcroppings, sinkholes, solution channels, and caves and on slopes greater than 7%.   Barring that, minimum buffers around all environmental features listed in Table 2 should at least equal the 35 foot buffer required by NRCS standards, regardless of the method of application.

It is difficult to tell whether these proposed regulations require prior notification to the local government of the exact date of application.  The regulations should explicitly require the permit holder to notify counties of specific delivery dates for any sewage sludge being applied in the county and the specific locations within the county where it will be applied.

9VAC25-32-560 - Because many soils in the Chesapeake Bay region contain very high concentrations of phosphorus due to long-term application of manure, chicken litter and commercial fertilizer, Dr. Evanylo recommends applying sludge at rates to meet the phosphorus needs of the crops (Virginia Cooperative Extension Publication 452-300).  If this is not a requirement of the nutrient management plans, the proposed regulations should be revised to make this a requirement of any permit. Virginia is under increasing pressure to reduce its phosphorus contribution to the Chesapeake Bay.  Permitting application of excess phosphorus in the form of sludge is counter to that goal and may necessitate further expenditures by the Commonwealth and our towns to reduce their phosphorus loadings.  

There is no provision in the state constitution that requires the state to provide easy disposal of sewage sludge or that entitles farmers or others to receive free fertilizer.  However, Article XI, Sec. 1 of the Constitution of the State of Virginia establishes that it is “the Commonwealth’s policy to protect its atmosphere, lands and waters from pollution, impairment or destruction, …”  Pursuant to that, Virginia State Code Section 62.1-44.19:3.B requires that the State Water Control Board  “… adopt regulations to ensure that …ii)land application, marketing, and distribution of sewage sludge is performed in a manner that will protect public health and the environment; and iii) the escape, flow or discharge of sewage sludge into state waters, in a manner that would cause pollution of state waters … shall be prevented.”   As was concluded by the Panel of Experts and reinforced by the EPA study on sewage sludge, much additional information is needed to ensure protection of health and the environment.   DEQ and the State Water Control Board should use all the flexibility they have available to them under federal and state law to regulate the use of biosolids within the Commonwealth in a manner that actually ensures those protections.

Sincerely,

Leslie Mitchell-Watson

Executive Director

Friends of the North Fork of the Shenandoah River

http://www.celdf.org/democracy-school

There should be no sludge applied to lands that support any kind of crop whether animal or vegetable.  There is simply inadequate testing and oversight.  There are too many anectdotal events, ailments and problem associated with sludge to ignore.  Please do not allow sludge to be used by any one for any reason at this time.

Thank you, Delano Kreis

Kern can stop Southland's sludge invasion

It all started off innocently enough. A Northern California city had a sludge problem and was looking for the most cost-effective way of getting rid of it. Between 1958 and 1973, the city of Livermore touted the city's sewage sludge as a great fertilizer for gardens and landscapes, and offered it to residents for free.

Unbeknownst to residents who trusted city officials, the sludge is believed to have been contaminated by plutonium released from the Lawrence Livermore National Laboratory into the city's sewer system.

In a small town in Pennsylvania, Antoinette and Russell Pennock thought the farm next to their home was innocently spreading cow manure on nearby fields. Not until their son, Daniel, died in 1995 of a massive bacterial infection did they realize that the farmer was spreading sewage sludge. Danny, 17, died from an infection he got after walking on land thick with sludge.

And in 2002, the family of Shayne Conner, a New Hampshire man who died in 1995 after being exposed to sludge, received an undisclosed settlement from a wrongful death lawsuit filed against Synagro Technologies. Synagro is the nation's largest sludge company and the parent of the South Kern Industrial Center that plans to build a sewage sludge-composting plant seven miles east of Taft.

Officials at Synagro claim that they settled out of concern for the victim's family and point to a statement that the family issued absolving sewage sludge as the cause of Shayne's death. Synagro officials later acknowledged that the company helped draft the statement and the Conner family signed it as a condition of the settlement.

Major health and environmental catastrophes start off innocently. First they tell us: Don't worry. It's safe. The science of the day can't prove that it's harmful.

Then people start getting sick, so we come up with new "safety" regulations. And finally when folks start to die, we're told that alternatives to cleaning up the mess will only cause worse damage so we just have to live with it and there is nothing that we can do about it.

Sound familiar? After years of allowing sanitation departments in Los Angeles and Orange counties to yearly dump over 450,000 tons of sewage waste on local farmland, we're told that we can't do anything about it. Never mind that the sewage sludge is spread over land above valuable water reserves.

Never mind that all it takes is one incident, one illness, one infection or one case of contamination of our groundwater for the market for all our valley crops to plummet and a quarantine to be imposed on us. Just look at what one case of mad cow disease did to the cattle and dairy industries around the world.

But what's most troubling about this situation is that it's simply not just the waste generators and haulers who are saying that we can't stop it. Unbelievably, it's our own elected county supervisors the folks who have the power to determine land use.

Twelve counties in California ban or effectively block the land application of sewage sludge. Why them and not us? Our county has too often innocently welcomed outside polluters. Rather than asking tough questions, putting forward tough public protection rules and being true conservatives with our land, they liberally fall on the side of the polluters claiming that we can't do anything about it.

It's time that our elected county officials stop acting so innocently. And it's time that we stop the culture of helplessness. What can county officials do immediately?

**First of all, they can support my legislation (Senate Bill 926) to ban the importation of sewage sludge across county lines. The proposed law says that each county needs to take care of its own sewage sludge.

**Secondly they can pass an ordinance to simply ban the land application of sewage sludge. An opinion from the Legislature's legislative counsel says that it can be done.

**And lastly, they can re-evaluate the conditional-use permit for the massive Synagro sewage composting plant slated for construction next to Taft. Holding a more publicized and public meeting on the permit and the company's plans would be a good start.

Kern County has hung out the welcome mat to sludge peddlers for far too long. We've seen the deaths and the effects sludge is having in communities across our country. Simply saying that we can't stop it isn't good enough. If our supervisors are not ready to pull the welcome mat from the feet of the sludge peddlers, then they run the risk of having the mat pulled out from beneath their feet when the voters finally get their hands on the situation through the initiative process.

Continued (including references) in Second Half

T

I would like to associate myself with the comments made by Dave Gibson.  There is no way to guarantee that every application of sludge is safe.  Not everything that goes down our drains can be safely sanitized for use on our food.  To equate sludge to what we normally think of as biosolids is just an attempt to fool the public.  Let's concentrate on finding alternative uses for human waste rather than risking the health of our people.  

The biological, microbiological and chemical concerns are legion in the unresolved biosolid issue, but, the one area that seems to be overlooked is the impact biosolids have on Virginia's Tourism Industry.  Virginia boasts "Virginia is for Lovers", but, I question the lovers who are down wind from recently applied biosolids.  The odors from these applications are beyond  description.

Environmental awaremess has increased significantly over the past few decades, and, "dumps " of years gone by are now regulated and monitored landfills.  Could it be with landfills reaching capacity, the solution is to "dump" above ground.  Surely not!!